Assess whether a referral to counsel is warranted (0f35c6)

Situation

Revenue Integrity work in a pre-IPO SaaS company drafting an S-1 now turns on a referral to counsel is warranted because a new counterparty formed 19 days before quarter-end put AP vendor-master change log in play. FCPA investigation lead should say what AP vendor-master change log proves.

Decision

FCPA investigation lead in a pre-IPO SaaS company drafting an S-1 must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using AP vendor-master change log after a new counterparty formed 19 days before quarter-end.

Hypotheses to test

• The population in AP vendor-master change log is the one a new counterparty formed 19 days before quarter-end named, so Remove access or reverse the item follows for this Revenue Integrity file.
• The population in AP vendor-master change log is adjacent only to a new counterparty formed 19 days before quarter-end; Temporary compensating control is the honest Forensic Accounting call.
• A pre-IPO SaaS company drafting an S-1 already contained a new counterparty formed 19 days before quarter-end before AP vendor-master change log arrived; no new Revenue Integrity path.
• Provenance on AP vendor-master change log after a new counterparty formed 19 days before quarter-end is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Trace approval, SoD, and related-party links that AP vendor-master change log actually shows.
• Test cutoff, reversals, and system-of-record ties for materiality on a referral to counsel is warranted.
• Quantify the entry if FCPA investigation lead has to reverse it.
• For this Forensic Accounting Revenue Integrity file, read AP vendor-master change log against a new counterparty formed 19 days before quarter-end and write the one fact that would move a referral to counsel is warranted for FCPA investigation lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Revenue Integrity packet (AP vendor-master change log after a new counterparty formed 19 days before quarter-end). The follow-on Revenue Integrity action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.